The role of the Nominated Individual – Are you the Registered Manager and the Nominated Individual?
Across the sector many registered managers take the dual role of also being the nominated individual. Almost half of all nominated individuals are also registered managers, both roles have different responsibilities, and it is important that if you have this dual role, you know and understand those different responsibilities and set yourself some boundaries.
The nominated individual has no statutory powers set out by CQC, but the role does have specific expectations which can get blurred when the registered manager takes both roles. The nominated individual is responsible for overseeing the management of the registered service, which may include carrying out mock inspections, audits, observations and other quality control activities. They need to have the oversight of the organisation; they should be aware of the risks and challenges as well as the successes and look to the RM to lead the service through any regular quality checks and areas of improvement.
The RM has the responsibility to carry out audits and even mock inspections, however the RM role is to oversee the day-to-day management of the service, to ensure they are delivering safe quality care for the people they support and their workforce, reviewing the care service delivery and implementing changes and improvements. Where a RM takes this dual role, they will need to think about how they represent any applicable evidence to the CQC that shows boundaries are understood and systems are in place to support both roles.
One of the roles of the NI is to supervise the RM and offer support to the registered manager as appropriate, and supervise the RM. Where this is a dual role, the RM should look for alternative ways of having their own supervision, this could be through peer supervision as a solution.
The concerns for CQC
One of the concerns for the CQC is recognising that the role of the NI is to supervise the RM, should there be a concern or issue with the RM then the CQC have no alternative senior role to escalate concerns to, processes will need to be in place to assure CQC who they should liaise with in such circumstance. For the organisation there is an additional concern should the RM leave, the NI role is also leaving the organisation.
In the case of the RM also taking the role of the NI then look to the organisation to have alternative systems and support mechanisms set up to allow any additional support to the RM, consider how the RM will gain that vital supervision time, and look at reporting systems that encourage the RM to separate any auditing or management oversight reports that sit within the role of the Nominated Individual from their own role as the Registered Manager.
If you have questions or need support on any of the issues raised in this blog, W&P are here to help. Our team has extensive experience in social care, with particular expertise in policies and procedures, and regulatory compliance. For more information or to talk with a member of the team, contact W&P on 01305 767104.
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